G.R. No. 70895. August 5, 1985.
HABALUYAS ENTERPRISES, INC. and PEDRO J. HABALUYAS, petitioners, vs. JUDGE MAXIMO M. JAPZON, Manila Regional Trial Court, Branch 36; SHUGO NODA & CO., LTD. and SHUYA NODA, respondents.

FACTS

In Civil Case No. 82-3305, the respondents (plaintiffs) received on October 1, 1984, a copy of the trial court’s order dated September 3, 1984, which denied their motion for execution of a judgment based on a compromise. The fifteen-day period to file a motion for reconsideration of this final order thus commenced. On the last day of this period, October 16, 1984, the respondents did not file their motion for reconsideration. Instead, they filed a motion seeking a twenty-day extension of time to submit it.
Subsequently, on October 23, 1984, the respondents filed their motion for new trial, coupled with a “conditional” notice of appeal. The petitioners (defendants) opposed the motion for extension and moved to dismiss the conditional appeal. Contrary to the petitioners’ opposition, Judge Maximo M. Japzon issued an order on April 29, 1985, granting the motion for new trial. It is this order that the petitioners assail before the Supreme Court in this certiorari proceeding.

ISSUE

Whether the fifteen-day period for filing a motion for reconsideration of a final order or ruling of the Regional Trial Court may be extended.

RULING

No, the fifteen-day period is non-extendible. The Supreme Court granted the petition, reversing and setting aside the trial court’s order granting a new trial. The Court held that the trial court erred in granting the motion for new trial because the motion for reconsideration, which was a prerequisite, was filed out of time. The filing of the motion for extension on the last day of the reglementary period did not toll or suspend the running of that period.
The legal logic is anchored on the mandatory and jurisdictional nature of procedural periods for appeal or reconsideration. Even under the old Rules of Court, the thirty-day period for such actions was held to be non-extendible, as established in precedents like Gibbs vs. Court of First Instance of Manila and Roque vs. Gunigundo. This strict construction is reinforced by Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980), which explicitly reduced the appeal period from thirty to fifteen days. The legislative intent behind this reduction was to expedite the judicial process and eliminate procedural delays. Allowing extensions would defeat this purpose and undermine the law’s objective of a speedy and inexpensive administration of justice. Therefore, the fifteen-day period is absolute and cannot be extended by the court. Since the motion for reconsideration was not filed within this inflexible period, the subsequent motion for new trial and the conditional appeal had no legal basis.